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Trump Administration’s America First Investment Policy to Bring Changes to CFIUS and Outbound Investment Reviews

Below is a summary of some of the measures identified in the Policy, and some suggestions for what foreign and domestic investors should be considering as this goes into effect....more

New (and Extended) Statute of Limitations for Many Sanctions Violations Enforced by OFAC

New OFAC Guidance on Statute of Limitations - On July 22, 2024, the Office of Foreign Assets Control (OFAC) published new guidance addressing how it intends to apply a recent change in the statute of limitations for...more

Additional Export Restrictions to Russia and Belarus: BIS Announces Additional Export Sanctions Against Russia and Belarus and...

On June 12, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) announced several significant additional export control restrictions and related actions against Russia as a response to continued...more

G-7 Summit Kicks Off With New Russian Sanctions

As the 49th Group of Seven (G7) Summit gets underway in Japan, the United States, in coordination with several other G7 members, marked the occasion to announce sweeping new sanctions and export controls aimed at “further...more

One-Year Anniversary of Russian Invasion of Ukraine Brings New Sanctions, Export Controls and Tariffs

On February 24, 2023, the White House marked the one-year anniversary of the Russian invasion of Ukraine by announcing a sweeping package of new sanctions, export controls and tariffs aimed at “holding Russia accountable for...more

Russian Sanctions/Export Controls Update: OFAC and BIS Expand Restrictions

Seven months into Russia’s invasion of Ukraine, the United States continues to expand and develop its Russia sanctions program. Most recently, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC)...more

Russian Sanctions/Export Controls Update: U.S.-European Sanctions/Export Control Measures Continue to Mount

The Russian invasion of Ukraine is continuing to prompt escalating sanctions and export controls on both sides of the Atlantic. Our team breaks down the latest measures coming out of the European Union, the United Kingdom and...more

Russian Financial Sector Sanctions: A Summary

The international sanctions targeting the Russian Federation include significant financial sanctions against Russian banks. We’re monitoring these actions and have created a summary of financial sanctions against Russian...more

Russian Sanctions/Export Controls Update: New Targets Identified

As the Russian invasion of Ukraine continues to escalate, the U.S. and its allies are still implementing (and considering) additional sanctions and export control measures aimed at isolating Russia’s economy and weakening...more

Russian Sanctions/Export Controls Update: The Second Tranche

In the immediate wake of Russia’s full-scale invasion of Ukraine, President Biden announced a package of sweeping economic sanctions and export control measures intended to “impose severe costs on the Russian economy, both...more

Russian Sanctions and Export Controls Update

On February 21, 2022, President Biden issued an Executive Order (EO) imposing new sanctions and export controls in response to Russia’s formal recognition of the so-called Donetsk People’s Republic (DNR) and Luhansk People’s...more

Forced Labor Enforcement: Xinjiang-Based Solar Panel Materials Become the Latest Regulatory Target

In an anticipated move, the Biden administration escalated its forced labor enforcement efforts on June 24 by announcing the issuance of a new withhold/release order (WRO) that blocks the import of certain polysilicon-based...more

EO Bans Transactions in Publicly Traded Securities of ‘Chinese Military-Industrial Complex’ Companies

On June 3, 2021, President Biden issued an Executive Order (EO) amending former President Trump’s November 12, 2020, EO 13959, which prohibited U.S. persons from engaging in certain transactions concerning the publicly traded...more

Biden Administration Completes its Second 50 Days With Continued Pressure on Targeted Countries Using Increased Sanctions and...

The Biden administration continues to utilize United States trade sanctions and export controls as a key tool in its efforts to put pressure on China, Myanmar/Burma and Russia. Since our last update, actions by the U.S....more

Sanctions Update – The First 50 Days

In its first 50 days, the Biden administration has been busy utilizing sanctions and export controls to support its foreign policy priorities of human rights, multilateralism and support for democratic regimes. The U.S....more

Scope of U.S. Ban on Transactions in Securities of ‘Communist Chinese Military Companies’

On January 13, 2021, President Trump amended the November 12, 2020, Executive Order (EO) 13959 providing greater clarity to the scope of the EO’s ban on trading and investing in certain designated publicly traded securities...more

OFAC Releases Updated Fact Sheet on Application of U.S. Sanctions to Provision of COVID-19-Related Humanitarian Assistance

On April 16, 2020, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) released a 10-page document entitled “Fact Sheet: Provision of Humanitarian Assistance and Trade to Combat COVID-19.” This document...more

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